DJH715

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Everything posted by DJH715

  1. Thanks Shelli, BV and CN for all your help! I will let everyone know how this goes. I'm hoping when I send my answers and my Discovery that they will realize that I'm going to fight them and they will just not answer my discovery. When they don't answer after 30 days I will send a certified letter asking them to answer and if after 30 days they don't answer still I will file a motion to dismiss with prejudice for lack of evidence. Crossing fingers!
  2. Discovery and Production of Documents Web.pdf Here are my Discovery questions and request for Documents that I have come up with so far. I have 10 Interrogatories and 9 Request for Documents. I need help I want to have alot more so its not easy for them. I've attached what I have so far. Any help would be greatly appreciated on what else I can ask for. Thanks all for what you've done. I can request up to 35 of each.
  3. Answer to Interrogatories Website .pdfShelli and BV I've finished typing up my answers to the Interrogatories and Request for Documents. I'm going to try and upload the pdf file. Please let me know if everything looks good or if I need to change something.
  4. Thanks BV I will do that. I want to show that they have nothing that establishes I have a debt with them.
  5. In August 2010 when I received the first collection letter from the attorney's office for their client PRA, I had no clue who this company was. They didn't even reference anything about GE Money Bank or Walmart or any account number, etc. only PRA and I supposedly owed $38XX to them. I had never heard of this company who is now asking me for $38XX. I wrote a DV letter right away and sent it CMRRR asking who they were and that I wanted copies of any documentation of what debt was owed to them, and how this amount was calculated and proof of ownership. I received a letter back only stating the
  6. Sure BV80 Petition on Suit on Open Account The petition of Precision Recovery Analytics, Inc. organized and doing business under the laws of the State of Texas shows: 1. [Name], and individual of the full age of majority, domiciled in the City of Slidell, State of Louisiana, is indebted unto Prescision Recovery Analytics, Inc. for the amount of $3,887.67 plus attorneys fees, interest, and the cost of these proceedings as more particularly set forth herein. 2. [Name] entered into an agreement with PRA (i'll abbreviate from now on) or its assignor whereby defendant was/were granted the right
  7. Thanks Shelli, I will keep you posted on how this goes. Did you see my post about documentation answers #7 & #8 if I need to send copies to them or not.
  8. Oh by the way, in the original petition and any correspondence they have sent me they only reference their file number and never have referenced any account number supposedly that I had with GE Money. I don't think they even know a number.
  9. Yes I don't think this JDB that is suing me is the first one this supposed debt was sold to. There may be others before them, so they will need to get a complete chain of sales from Original creditor up until they bought the supposed debt. Is that the Bill of Sale that you are referring to?
  10. And thank you, thank you, thank you. I appreciate all your hard work and can't wait to send this back showing them that I will not fight back.
  11. #7 & #8 requests documents to or from any party (not just GE Money) regarding the subject of this lawsuit. I did send a DV letter to this attorney's office on September 7,2010 prior to them filing suit when I first heard of this JDB saying I owed them money. I sent that letter certified mail and received a response from the attorney's office on October 5, 2010 not answering my questions and only saying the original creditor was GE Money. I then sent another DV letter on October 11, 2010 stating that they did not validate the debt by sending me a copies of documents showing that Precision o
  12. Goodness, Thank you so much Shellie!!!!!!!! I'm going to type these up tomorrow. What do I put for the production of documents?
  13. Thanks Nascar for your response and link. I think I have 30 days to answer since I am the defendant and not just a party. That's if I'm reading Article 1458 correctly. I will use the date of the letter as a safe guard and not the date I received it. The discovery did come by regular u.s. mail non certified. I'm just trying to figure out how to word my objection to giving them my social security number, date of birth, employment information, spouse's same info and bank information. I feel this is priviledged information since they have not proven they even own this debt and I have to co
  14. Limit is 35 questions and document requests. Thanks so much for your help. November 8th will be 3 years since they filed their suit. SOL was 9/9/2009 but they filed suit in 2010 to preserve the SOL. From what I understand this request from them for Discovery is to keep their suit from being abandoned for non activity over the past 3 years. After I send them my answers and request discovery from them, what happens if they do not answer my request. If after 30 days they do not respond do I then have to send a letter requesting they cooperate and if still no response do I have to file with
  15. Plaintiff's First Discovery Request to Defendant Now into Court, through undersigned counsel, comes Plaintiff, Precision Recovery Analytics, Inc., who requests that Defendant respond to the following discovery requests within the time allowed under the Code or Rules of Civil Procedure. These discovery requests are continuing and Plaintiff requests that Defendant supplement and amend the responses if further information is obtained. Then Definitions are spelled out Interrogatories: 1. State your name, address, date of birth, place of employment and Social Security number. If you objec
  16. Thanks so much Shellih98. I appreciate your help. I definitly want to make them produce in my Discovery a copy of a document where they purchased the debt from GE Money Bank and how much they paid for that debt along with a breakdown of what is supposedly owed. I doubt they can produce that but I'm not about to let this company get a Judgment against me and not show proof that I OWE them and not GE Money Bank.
  17. I sent first DV letter and all they sent back was GE Money Bank Walmart as the original creditor and the address. I had asked for validation/proof of this debt and validation of the amount that they said was owed and how they arrived at the balance. I did not recieve any such proof. I then wrote another DV letter in response to their letter and requested this proof once again and have received nothing. Next thing I know I am served with a petition where they filed a lawsuit in November 2010 so I answered their petition and filed that with the courts. Since then I have periodically receive
  18. Plaintiff's First Discovery Request to Defendant Now into Court, through undersigned counsel, comes Plaintiff, Precision Recovery Analytics, Inc., who requests that Defendant respond to the following discovery requests within the time allowed under the Code or Rules of Civil Procedure. These discovery requests are continuing and Plaintiff requests that Defendant supplement and amend the responses if further information is obtained. Then Definitions are spelled out Interrogatories: 1. State your name, address, date of birth, place of employment and Social Security number. If you objec
  19. Yes I want to answer but want to protect myself. They are basically asking me to prove their case in these questions. This is a JDB that is suing me and I don't think they can show proof that they purchased the debt from GE Credit. They have filed the suit under their name and not GE Credit and when I answered the petition almost 3 years ago I stated I had no contract with the JDB and had never heard of them. I will post the Interrogatories and Document request that they are asking for and hope you can help with the answers. Then I also would like to send them a First Discovery Request of
  20. Thanks BV you are correct. I checked my states Civil Procedures and they are filing these Interrogatories just to keep the case alive. November will make the 3 year mark.
  21. I was served in Slidell, Louisiana November 2010 with a Petition in Suit on Open Account and served by the court with Precision Recovery Analytics as the Plaintiff. I had 10 days to answer the petition which I did and filed the petition with the courts a few days after being served. I also included my defenses to the petition and denied all allegations. The plaintiff is evidently a Junk Debt agency so I stated I had never heard of them and had no dealings with them. I also stated in my defenses that I had never entered into any contractual arrangement with them and that the plaintiff provi